DPO Service

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Appointing a Data Protection Officer (DPO)

Data Protection Officers (DPOs) support companies in the smooth implementation of and compliance with the GDPR. We provide your company with an experienced team of multilingual, certified data protection officers across Europe. Whether you are legally required to appoint a DPO or simply want to be on the safe side when navigating the GDPR, you will benefit from our years of expertise in data protection and IT security.

When does my company need a data protection officer?

For many companies processing data from the EU or EEA, the designation of a DPO is a legal requirement. The exact regulations vary from country to country within the EU. The flowchart below may serve as initial guidance. 


In general, a DPO must be appointed if data processing creates a high risk to the rights and freedoms of data subjects in the EU. This can be due to systematic monitoring (e.g. continuous GPS tracking of company cars), but also due to extensive processing of sensitive data (e.g. apps for recording habits/diet/fitness/sleep etc.). Sensitive data are special categories of personal data such as ethnic origin, religious, political and ideological beliefs, biometric, genetic and health data, as well as data on sexual orientation or sex life.
Furthermore, the use of AI technology (e.g. machine learning, neural networks, generative adversarial networks, large language models), as well as the handling of data of children or data on criminal offenses, can lead to a high risk. 

A query on German establishments is included in the flowchart due to Germany having the strictest requirements regarding the designation of data protection officers. In Germany, a DPO is required as soon as at least 20 employees are permanently involved in the processing of personal data (for example through regular e-mail communication).

Regardless of the need for a DPO, companies without an establishment in the EU often need an EU representative.

What does a data protection officer do?

According to Article 39 of the GDPR, data protection officers have the following mandatory tasks:

  • Informing and advising the company and employees on the GDPR and other data protection provisions
  • Monitoring compliance with all data protection requirements
  • Advising on data protection impact assessment
  • Cooperation with the supervisory authorities

What makes Enobyte excel

Enobyte's data protection officers take on a variety of additional tasks.
For instance, we support you in the event of data breaches (e.g. data loss, ransomware, theft, phishing), as well as in conducting risk assessments on projects and infrastructure in your company. We are also happy to support you in the planning and implementation of new IT projects. In doing so, we act as direct partners for the management and coordinate all necessary measures across the various departments. If new service providers are to be engaged, we evaluate their data protection compliance to ensure the security of your company. Furthermore, we ensure that you are always up to date in data protection matters by providing annual training for your employees in English, German or Japanese, as well as regularly reviewing and updating your data protection and IT security guidelines.

Our external DPO service further offers the following benefits:

  • No conflicts of interest harmful to the company
  • Many years of experience with various companies and industries
  • Well established in data protection and IT associations
  • 24/7 availability in case of incidents, even on Sundays and holidays
  • Practiced and professional crisis handling